MULTI-YEAR ACCESSIBILITY PLAN
This Accessibility Plan (the “Plan”) outlines the past, current and future actions of Channel Control Merchants/Treasure Hunt Canada (“Treasure Hunt”, “Channel Control Merchants” or the “Company”) as it takes steps to provide equal access and opportunity for people with disabilities.
This Policy applies to all The Company’s entities. All employees, contractors and other persons who interact with employees, the public or third parties on these entities’ behalf are expected to comply with this Policy.
The Company is committed to treating all people with respect and in a manner that allows them to maintain their dignity and independence. The Company believes in equal opportunity, strives to identify, remove, and prevent barriers to accessibility, and aims to meet accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and other relevant legislation.
The Company is further committed to promoting equality and providing employees with programs, support and opportunities irrespective of disability. In addition, The Company aims to ensure that all individuals have equal access to, and receive equal benefit from, its services.
ACHIEVEMENTS, PRACTICES & ACTION
The Company maintains an Accessibility for Ontarians Policy (the “Policy”) that addresses key areas of AODA compliance, including training, information and communication, employment standards, and the provision of services to people with disabilities.
As further outlined in the Policy, The Company has taken and continues to take action in the following areas to further its’ commitment to accessibility and accommodation of persons with disabilities:
The Company will provide its team members with training consistent with the Accessibility Policy. The Company acknowledges that the development and provision of training is an ongoing process that must continue to adapt to the needs of the Company and of persons with disabilities. This training will build on existing training relating to accessibility topics already delivered to employees. The Company will conduct an inventory of existing AODA and related training programs and review and update existing content to ensure the consistency of training programs throughout all of The Company locations.
The nature and content of the training provided may vary in accordance with the trainee’s role and responsibilities. Generally, training will include:
- the purposes of AODA and its requirements
- the Ontario Human Rights Code as it pertains to persons with disabilities
- how to interact, communicate and consult with people with various types of disabilities, including how to access and effectively use the various communication formats that The Company has available
- how to access and effectively use the various assistive devices that The Company has available
- how to accommodate individuals that require the assistance of a service animal or a support person
- how to provide, receive and escalate feedback provided with respect to accessibility questions and concerns
- The Company policies, practices and procedures relating to providing services to people with disabilities, as further outlined in the Providing Services to People with Disabilities section of this Policy
Training will be delivered to:
- new employees, most contractors, as well other persons who interface with employees, the public or third parties on The Company’s behalf and persons who participate in developing the Company’s policies
- existing employees and most contractors, as well other persons who interface with employees, the public or third parties on The Company’s behalf, and persons who participate in developing the Company’s policies, who have not previously received comparable training from the Company
The Company will maintain a record of the training provided, including the training dates, and the name and number of individuals to whom it was provided.
The Company may provide additional training as changes in legislation or workplace conditions require.
Information & Communication
The Company is aware if its obligations to provide persons with disabilities with accessible communication and currently supports a number of communication formats and assistive devices. The Company is further aware of its obligation to ensure that its websites meet AODA accessibility standards.
On an ongoing basis, The Company will take appropriate steps to:
- train team members to communicate over the telephone in clear and plain language and to speak clearly and slowly, and, are familiar with the various communication formats and assistive devices available to support persons with disabilities
- communicate with employees, customers and members of the public by e-mail or letter if telephone communication is not suitable to individuals’ communication needs or is not available
- encourage persons with disabilities to consult with The Company in person, by telephone or e-mail, in order to discuss additional accessibility formats that may be necessary to accommodate their individual needs
The Company will take necessary steps to meet the requirement to make all new websites and content on those new websites conform with WCAG 2.0, Level A. Existing websites and web content will conform with WCAG 2.0, Level AA by January 1, 2021 in accordance with the AODA.
The Company seeks to provide all candidates and employees with an equal opportunity to succeed, and so works to ensure accessibility for persons with disabilities throughout the recruitment and hiring process, as well as at the workplace. The Company has also developed policies to accommodate employees with disabilities, and processes to help employees to return to work after disability leave.
The Company is committed to furthering its objective to foster an inclusive workplace. As a result on an ongoing basis, The Company will take the following steps:
- upon an employee’s request, ensure that (a) any information that is required for an employee with a disability to perform the job for which they were hired, and (b) any other information that is generally available in the workplace, is made available in accessible formats and provides communication supports
- consult with employees with disabilities to determine what actions the Company can take to meet employees’ individual needs and to foster a more inclusive environment
- upon an employee’s request, provide an individual accommodation plan in accordance with the Individual Accommodation Plans: Process and Procedures Policywhere (a) The Company is aware that an employee requires accommodation due to disability, and (b) the disability is such that individual information is necessary for the employee’s safety and wellbeing, The Company will provide the affected employee with individual workplace emergency response information for emergency events such as fire, power outages or severe weather conditions
- assist employees in returning to work as soon as practicable after disability-related absences, subject to applicable law and other terms and conditions of employment or applicable agreements.
Additionally, The Company will review and if necessary revise its existing employment document templates (including job postings and offer letters) to ensure that these documents specify the accommodation and accessible formats that are available to people with disabilities throughout the recruitment and employment process.
The Company will also review and if necessary, revise its existing policies, procedures and practices relating to performance management and career development to ensure that employees’ accessibility needs are taken into account.
Provision of Services to People with Disabilities
The Company makes all reasonable efforts to ensure that people with disabilities have equal access to and obtain equal benefit from its services. The Company currently supports a number of communication formats and assistive devices to enable customers with disabilities to obtain accessible information. Training will be provided to staff as appropriate on how to effectively communicate with and assist customers with disabilities.
The Company is committed to furthering its’ objective to provide equal and high-quality service to customers with disabilities. As a result, on an ongoing basis, The Company will:
- encourage customers with disabilities to consult with The Company in person, by telephone or e-mail, to discuss additional accessibility formats that may be necessary to accommodate their individual needs, and to provide feedback with respect to Treasure Hunt’s accommodation efforts
- offer accessible billing and invoicing options to customers, to be provided in the following formats upon request: hard copy, large print or e-mail. The Company will answer any questions customers may have about the content of the invoice in person, by telephone or e-mail
- provide clients with notice in the event of a planned or unexpected disruption in the facilities or services usually used by people with disabilities. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available
- include on its websites and at its premises a notice advising clients how they can request a copy of this Policy and all related documents. The Company will strive to provide clients with disabilities who request a copy of this Plan or the Policy with a format that takes into account their disability
Further, The Company will review, and if necessary, revise its’ existing processes for receiving feedback from customers and members of the public with disabilities, to ensure that disabled individuals can provide feedback in a manner that meets their individual needs and that The Company has processes in place to effectively address this feedback.
This Policy will be reviewed by The Company at least every five years, and more frequently should legislative changes or changes to the workplace necessitate further review.
- Accessibility for Ontarians Policy
- Individual Accommodation Plans: Process and Procedures Policy
The Company is committed to developing policies that respect and promote the dignity and independence of people with disabilities. Therefore, no changes will be made to this Plan before considering the impact on people with disabilities.
For further information, contact The Company’s Human Resources department.